Hazard Communication Program: Why HazCom Is OSHA's #2 Most Cited Violation

16 min read
Hazard Communication Program: Why HazCom Is OSHA’s #2 Most Cited Violation

Your employee just mixed two cleaning chemicals. Toxic fumes filled the room. Now they’re in the ER with chemical burns and respiratory damage.

Nobody told them the chemicals were incompatible. There were no labels. No SDS safety data sheets. No training.

This happens every day in American workplaces. And it’s completely preventable.

Hazard Communication (HazCom) was the #2 most-cited OSHA violation in 2024. 2,888 violations across all industries. Average penalty: $7,000–$10,000 per violation.

Most businesses don’t realize they’re out of compliance until OSHA shows up. By then, the damage is done—to your workers, your wallet, and your workers comp costs.

If your business uses any chemicals—cleaning products, paints, solvents, oils, adhesives—you need a written hazard communication program. The OSHA Hazard Communication Standard (29 CFR 1910.1200) isn’t optional. It’s federal law.

Here’s why this matters for your business—and how to get a program in place fast.

Table of Contents

Why Chemical Exposure Destroys More Than Health

Chemical injuries are immediate. Severe. Life-changing.

The Human Cost

What happens to your employees:

  • Chemical burns (skin, eyes, respiratory)
  • Poisoning from inhalation or absorption
  • Long-term organ damage (liver, kidneys, lungs)
  • Cancer from carcinogen exposure
  • Asthma and chronic respiratory conditions
  • Permanent disability or death

Your workers don’t just get sick. They lose their ability to work. To breathe normally. To live without pain.

And most chemical injuries are caused by one thing: lack of proper chemical handling safety practices and information.

The Business Cost

What happens to your company:

Workers Compensation Claims:

  • Medical treatment and hospitalization
  • Ongoing care for chronic conditions
  • Wage loss during recovery
  • Permanent disability compensation
  • Death benefits to families

Experience Modification Rate Impact:

  • Chemical injuries = serious claims
  • EMR stays elevated for 3 years minimum
  • 15-30% premium increase per serious claim
  • Multiple violations = compounding impact

See our post on how your experience modification rate works.

OSHA Penalties:

  • $16,550 per serious violation
  • $165,514 per willful/repeated violation
  • Multiple violations cited simultaneously
  • Average penalties: $7,000–$10,000 per violation in practice

Operational Costs:

  • Emergency response and cleanup
  • Production downtime
  • Investigation time
  • Employee replacement and training
  • Reputation damage

One preventable chemical exposure can cost your business $100,000+ when you factor in medical costs, OSHA fines, EMR impact, and lost productivity.

Compare that to compliance: a written program, labels, and training. Maybe $2,000–$3,000 total, much less if using the Smarter Risk Platform.

What Is a Hazard Communication Program?

A hazard communication program (HazCom program) is your written plan for identifying, labeling, and communicating chemical hazards to employees.

The OSHA Hazard Communication Standard requires it when you have ANY hazardous chemicals in your workplace.

That includes:

  • Cleaning products
  • Paints and coatings
  • Solvents and degreasers
  • Oils and lubricants
  • Adhesives and glues
  • Pesticides
  • Fuels
  • Manufacturing chemicals
  • Any product with a warning label

If you can buy it at a hardware store and it has a hazard pictogram, you need HazCom compliance.

Understanding the Globally Harmonized System (GHS)

Before we dive into OSHA requirements, you need to understand GHS—the Globally Harmonized System of classification and labeling of chemicals.

GHS is the international standard for chemical hazard communication. OSHA adopted it in 2012 to align with worldwide standards. This is why all chemical labels and safety data sheets (SDS) now look consistent.

The GHS labeling system includes:

  • Pictograms - Standardized hazard symbols
  • Signal words - “Danger” (severe) or “Warning” (less severe)
  • Hazard statements - Describes the specific hazard
  • Precautionary statements - How to minimize risk

Hazard Pictograms Meaning

The GHS uses nine standardized pictograms—red diamonds with black symbols—to identify chemical hazards:

GHS Hazard Pictograms Chart
  • Flame - Flammable materials
  • Flame over circle - Oxidizers
  • Exploding bomb - Explosives
  • Gas cylinder - Compressed gases
  • Skull and crossbones - Acute toxicity (can be fatal)
  • Corrosion - Corrosive to metals, skin, eyes
  • Exclamation mark - Irritant, harmful
  • Health hazard - Carcinogen, respiratory sensitizer, reproductive toxicity
  • Environment - Environmental hazard

Understanding these hazard pictograms and their meanings is critical for chemical handling safety. Your employees must recognize these symbols instantly and know what protective measures to take.

OSHA Hazard Communication Standard: What You Must Do

The OSHA Hazard Communication Standard (29 CFR 1910.1200) has specific requirements. Miss any of them, and you’re in violation.

1. Written Hazard Communication Program

You must have a written hazard communication program that describes:

  • How you’ll label containers
  • How you’ll maintain SDS safety data sheets
  • How you’ll train employees
  • Your chemical inventory
  • How you inform contractors of hazards

Most common HazCom violation: lack of a written program.

The program must be site-specific. Generic templates don’t cut it.

2. Chemical Inventory

Maintain a current list of ALL hazardous chemicals on-site:

  • Chemical name (as it appears on SDS)
  • Manufacturer
  • Location where used/stored
  • Quantity
  • Work areas where present

Update this list whenever:

  • New chemicals arrive
  • Chemicals are discontinued
  • Usage changes
  • Locations change

Review at least annually.

3. Labels and Warnings (GHS Labeling System)

Every chemical container must have a label with:

  • Product identifier
  • Signal word (Danger or Warning)
  • Hazard statements (describes the hazard)
  • Precautionary statements (how to minimize risk)
  • Pictograms (standardized hazard symbols)
  • Supplier information

This includes:

  • Original manufacturer containers
  • Secondary containers (spray bottles, buckets, smaller containers)
  • Transfer containers
  • Temporary storage

Missing labels on secondary containers are among the most common violations. The GHS labeling system applies to ALL containers, not just original packaging.

4. Safety Data Sheets (SDS)

You must have SDS safety data sheets for every hazardous chemical:

  • Readily accessible to employees during all shifts
  • Available in their work area
  • Electronic or paper format (both acceptable)
  • No login required for access
  • Current and up-to-date

Each SDS contains 16 sections:

  1. Identification
  2. Hazard identification
  3. Composition/ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/PPE
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information

Missing SDS safety data sheets for chemicals is a frequent citation. You need them for EVERY hazardous chemical, including common cleaning products.

5. Hazard Communication Training

Train employees on:

  • Chemical hazards in their work area
  • How to read labels and SDS safety data sheets
  • Protective measures (PPE, ventilation, handling)
  • Emergency procedures
  • Location of SDSs
  • Physical and health hazards of chemicals
  • How to recognize hazard pictograms

Training required:

  • Before initial assignment
  • When new chemical hazards are introduced
  • Annual refreshers (best practice)

No hazard communication training is one of the most cited HazCom violations.

Training must be documented. Who attended, what was covered, and when it occurred.

6. Multi-Employer Workplaces

If contractors work on your site:

  • Provide them with SDS safety data sheets for the chemicals they may encounter
  • Inform them of hazardous chemicals in their work areas
  • Tell them about labeling systems and protective measures
  • Request their SDSs if they bring chemicals on-site

If they bring chemicals:

  • Get their SDS safety data sheets
  • Inform your employees of contractor chemicals
  • Coordinate protective measures

Chemical Handling Safety: Best Practices Beyond Compliance

Meeting the OSHA hazard communication standard is the minimum. Effective chemical handling safety goes further.

Safe Chemical Storage

Segregation:

  • Separate incompatible chemicals
  • Never store acids with bases
  • Keep oxidizers away from flammables
  • Use chemical compatibility charts

Organization:

  • Store chemicals at or below eye level
  • Use secondary containment for liquids
  • Keep containers closed when not in use
  • Post hazard signs on storage areas

Chemical Transfer Procedures

Every time you transfer a chemical:

  • Label the new container immediately using the GHS labeling system
  • Use appropriate PPE
  • Work in ventilated areas
  • Keep SDS safety data sheets accessible
  • Use proper transfer equipment (funnels, pumps)
  • Have spill response materials ready

Emergency Response

Before using any chemical:

  • Read the SDS safety data sheets
  • Understand first aid measures
  • Know spill response procedures
  • Have emergency contact numbers posted
  • Ensure emergency equipment accessible (eyewash, shower, fire extinguisher)

Common Mistakes That Trigger OSHA Citations

Mistake #1: No Written Program

“We train people” doesn’t count. The OSHA Hazard Communication Standard requires a written hazard communication program. No exceptions.

Mistake #2: Missing Secondary Container Labels

Original containers have GHS labels. Your spray bottles, buckets, and transfer containers? Those need GHS-compliant labels, too. Simple fix: take a picture of the orginal label, print it, tape it to the secondary containter. Done.

Mistake #3: Inaccessible SDS Safety Data Sheets

“They’re in the manager’s locked office” isn’t accessible. Employees need immediate access to SDS safety data sheets during their shift.

Mistake #4: Generic Training

“Here’s where the SDSs are” isn’t hazard communication training. Cover specific chemicals, hazards, hazard pictograms meaning, and protective measures for your workplace.

Mistake #5: Outdated Chemical Inventory

You stopped using that solvent two years ago, but it’s still on the list. Or worse—you’re using new chemicals not on the list.

Mistake #6: Ignoring Contractors

They brought chemicals on-site. They’re working near your chemicals. Nobody communicated any information about chemical-handling safety.

Mistake #7: No Training Documentation

“We trained everyone,” with no records, means you didn’t train anyone in OSHA’s eyes.

How Smarter Risk Makes This Simple

Building a compliant hazard communication program used to mean months of work—researching the OSHA hazard communication standard, finding templates, customizing everything, hoping you didn’t miss anything.

Not anymore.

Build Your Policy in Minutes

Smarter Risk’s Policy Builder generates a complete, OSHA-compliant hazard communication program based on your risk assessment.

What you get:

  • Complete written program (29 CFR 1910.1200 compliant)
  • Chemical inventory template
  • Contractor acknowledgment form

Download in Word format. Customize if needed. Implement immediately.

What’s Included with Smarter Risk

Intelligent Plan ($500/year):

150+ Safety Forms

  • Chemical inventory template
  • Contractor acknowledgment form
  • SDS request forms
  • Training documentation templates
  • Incident report forms

52 Training Courses

  • Hazard Communication Training (directly relevant)
  • Personal Protective Equipment (PPE) Safety Training
  • Bloodborne Pathogens Safety Training
  • Respiratory Protection Training
  • 48+ additional courses

View the complete course catalog at smarterrisk.com/training.

Policy Builder

  • Hazard Communication Program
  • PPE Policy
  • Respiratory Protection Policy
  • Bloodborne Pathogens Policy
  • 20+ other safety programs

Implementation: Your 30-Day Plan

Don’t let this sit on a shelf. Here’s how to implement fast:

Week 1: Document and Assess

  • Complete your risk assessment with Smarter Risk
  • Generate your hazard communication program
  • Create your chemical inventory (list every hazardous chemical)
  • Verify you have SDS safety data sheets for all chemicals

Week 2: Labels and Access

  • Label all secondary containers using the GHS labeling system
  • Verify all primary containers have proper labels
  • Set up SDS access system (binder, electronic, or both)
  • Post hazard communication program location information

Week 3: Train Your Team

  • Conduct initial hazard communication training for all employees
  • Cover specific chemicals in their work areas
  • Show them where SDS safety data sheets are located
  • Explain the GHS labeling system, the meaning of hazard pictograms, and emergency procedures
  • Review chemical handling safety procedures

Week 4: Finalize and Monitor

  • Complete contractor notification procedures
  • Post required information
  • Document all training
  • Schedule annual review

Ongoing

  • Update inventory when chemicals change
  • Train new employees before chemical exposure
  • Annual training refreshers
  • Annual program review
  • Update chemical handling safety procedures as needed

The Bottom Line

Chemical exposures are immediate and severe. Unlike hearing loss or repetitive strain, one incident can permanently disable a worker or end their life.

A hazard communication program prevents these tragedies. It’s required by the OSHA Hazard Communication Standard. It protects your workers. It protects your business from devastating claims that raise your experience mod for years.

HazCom is the #2 most-cited OSHA violation because most businesses either don’t have a written hazard communication program or don’t implement proper chemical-handling safety practices.

With Smarter Risk, implementation takes minutes instead of months. For $500/year, you get a complete hazard communication program that meets all requirements, plus training and forms.

One prevented chemical injury pays for itself 200x over.

Build Your Hazard Communication Program Today

Don’t wait for an OSHA inspection. Don’t wait for a chemical injury.

Start your free risk assessment and generate your complete hazard communication program in minutes.

Or explore our Safety Made Simple approach to building comprehensive safety programs from scratch.

FAQs

What chemicals require a hazard communication program?

Any chemical that presents a physical or health hazard. This includes cleaning products, paints, solvents, fuels, oils, adhesives, and manufacturing chemicals. If the product has a hazard warning label or pictogram, it’s covered by the OSHA Hazard Communication Standard.

Do I need a written hazard communication program?

Yes. The OSHA hazard communication standard requires a written hazard communication program if you have any hazardous chemicals in your workplace. The program must be site-specific and describe how you comply with labeling, SDS, and training requirements.

What is the globally harmonized system (GHS)?

The Globally Harmonized System (GHS) is the international standard for classifying and labeling chemical hazards. OSHA adopted GHS in 2012 to align with worldwide standards. The GHS labeling system includes standardized pictograms, signal words, hazard statements, and precautionary statements on all chemical labels.

What’s the difference between primary and secondary container labels?

Primary containers are original manufacturer containers with GHS-compliant labels already attached. Secondary containers are any containers you transfer chemicals into (spray bottles, buckets, smaller containers). Both need labels following the GHS labeling system with the same hazard information.

Where should I keep SDS safety data sheets?

SDS safety data sheets must be readily accessible to employees during all shifts in their work area. This means a binder in the work area, electronic access on a computer in the area, or both. Employees cannot be required to ask permission or leave the area to access SDS safety data sheets.

How often do I need hazard communication training?

Initial hazard communication training should be provided before employees work with hazardous chemicals. Additional training is required when new chemical hazards are introduced. Annual refresher training is best practice, though the OSHA hazard communication standard doesn’t specify a frequency for refreshers.

Do contractors need to follow my hazard communication program?

Yes, if they work on your site. You must inform them of hazardous chemicals in areas where they’ll work and provide access to relevant SDS safety data sheets. If they bring chemicals on-site, they must inform you and provide their SDSs.

What happens if I don’t have a hazard communication program?

OSHA citations and fines ($7,000–$10,000 per violation on average, up to $165,514 for willful violations). Increased risk of chemical injuries. Workers comp claims. Higher insurance costs. Potential lawsuits. Possible criminal charges if someone dies.

Can I use electronic SDS safety data sheets instead of paper?

Yes. Electronic SDS safety data sheets are acceptable as long as: (1) employees have immediate access, (2) no login or permission is required, (3) they are available during all shifts, and (4) they are accessible in their work area. Many companies use both electronic and paper backup.

How do I handle chemicals that come without SDS safety data sheets?

Contact the manufacturer or supplier immediately and request the SDS. Do not allow employees to use the chemical until you have the SDS safety data sheet. Keep records of your requests. If the supplier cannot provide an SDS, find an alternative chemical.

What do the hazard pictograms mean?

Hazard pictograms are standardized GHS symbols that identify chemical hazards: flame (flammable), skull and crossbones (toxic), corrosion (corrosive), exploding bomb (explosive), gas cylinder (compressed gas), health hazard (carcinogen/respiratory), exclamation mark (irritant), environment (environmental hazard), flame over circle (oxidizer). Understanding the meanings of hazard pictograms is essential for chemical-handling safety.

What are the most important chemical handling safety practices?

Key chemical-handling safety practices include: reading SDS (safety data sheets) before use, using proper PPE, storing incompatible chemicals separately, labeling all containers using the GHS (Global Harmonizing System) labeling system, working in ventilated areas, keeping emergency equipment accessible, and following proper transfer procedures.

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About the Author

John Morlan - Founder of Smarter Risk

John Morlan

Founder & CEO, Smarter Risk

John Morlan is the founder of Smarter Risk, a platform helping small businesses implement practical safety and risk control programs. With years of experience in workers' compensation and risk management, John has helped businesses reduce their risk and save on insurance costs through proactive risk control and safety strategies.